Bank

Bank

Recognizing unusual transactions

As a service provider – bank – you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your judgment is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.

If a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.

Red flags – Bank

  • A cash transaction in small denominations, with uncounted money, in unusual packaging;
  • Frequent deposits by parties other than the account holder, which are not suitable for the client’s profession or activities
  • The client is nervous for no apparent reason
  • There is a noticeable revenue on the account, which is disproportionate to the client’s profession or activities or business activities
  • Incoming payments, originating from typical offshore financial centers
  • Outgoing payments go to parties / countries that do not fit the client’s profile

Regulations:

Regulation regarding an order for the extradition of MTC documents

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